Recently, the Food and Drug Administration’s Office of Prescription Drug Promotion (“OPDP”) issued two Notice of Violation (“NOV”) letters in one day. Foreigner’s 1978 “Double Vision” album and title track come to mind. Both NOVs focus on direct-to-consumer (“DTC”) promotion. We highlight the main issues and offer our own observations in this Bulletin….
By: Arnall Golden Gregory LLP
By: Arnall Golden Gregory LLP